In 1964, Fact Magazine produced a special issue entitled “The Unconscious of a Conservative: A Special Issue on the Mind of Barry Goldwater,” specifically addressing the mental health of then-Republican presidential candidate Sen. Barry Goldwater. As would be expected, the magazine did not pronounce Goldwater with a clean bill of mental health. Rather, it essentially pronounced him unfit for office and speculated into the inner workings of his mind. Goldwater sued the editor of the magazine for libel and was awarded $75,000.

In response to this incident, in 1973, the American Psychiatric Association (APA) produced a code of ethics specifically applicable to psychiatrists that contained a provision that is now widely known as the Goldwater Rule. This rule states that it is unethical for a psychiatrist to speculate about the mental health of a public figure unless the psychiatrist has examined the public figure personally and has permission from the public figure to share his opinions.